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To run a useful healthcare emergency preparedness drill, start with your facility’s risk assessment and emergency plan, choose one or two capabilities to test, assign clear exercise and safety roles, observe performance against measurable objectives, and turn findings into corrective actions with owners and retest dates. First confirm the exercise schedule and accepted formats for your facility’s specific Medicare or Medicaid certification category; the hospital requirement is not universal.
Start with your facility’s requirements, risks, and plan
Before scheduling an exercise, identify the facility’s certification category and check the current federal rule and provider-specific guidance that apply to it. State and local requirements and accreditation standards may add obligations. CMS’s Emergency Preparedness Rule applies across provider and supplier types, but its exercise requirements vary; consult the relevant regulation, Appendix Z, and provider materials rather than assuming that a hospital’s schedule applies to every setting. CMS Emergency Preparedness Rule and CMS provider guidance are starting points.
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For a Medicare-participating hospital, 42 CFR 482.15(d) ties its training and testing program to the emergency plan, risk assessment, policies and procedures, and communication plan. Use the same facility-specific foundation to choose what to exercise: a drill should test a response the facility might actually need, not just walk participants through a generic scenario. The 2024 edition of 42 CFR, including section 482.15, sets out the hospital requirements cited here; verify the current text for your certification type.
Choose a local hazard and a capability to test
Review the facility’s hazard vulnerability analysis or other risk assessment alongside its emergency plan. Select a plausible local threat and identify a capability the exercise can examine, such as activating the response structure, notifying staff, using backup communications, evacuating or sheltering patients, tracking patients, requesting mutual aid, or maintaining critical services. Include community response partners when coordination with them is part of the objective or would make the test more useful. ASPR recommends using identified gaps to guide exercise design and coordinating with response partners where appropriate. ASPR’s preparedness capabilities describes that improvement cycle.
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Write observable objectives
Keep the objectives focused enough for evaluators to observe and document. For example: “The incident lead will activate the facility response structure and notify designated department leads using the primary or backup method,” or “The care team will account for patients during a simulated unit evacuation and report status through the facility’s patient-tracking process.” An objective should make clear what action or decision counts as evidence; “practice emergency response” is too broad to evaluate consistently.
Choose an exercise format that fits the objective
Exercise types differ in how much participants do, how much coordination is tested, and what resources are needed. Choose the format for the capability you want to assess, then confirm it is permitted for your provider category and required exercise cycle. CMS describes exercise formats and acceptable alternatives in its emergency preparedness guidance; the applicable rule, not the format’s name alone, determines whether a particular exercise satisfies a requirement. CMS memorandum QSO-21-15-ALL and CMS interpretive guidance provide further detail.
| Format | What participants do | Useful for | Planning consideration |
|---|---|---|---|
| Tabletop exercise | A facilitator presents a narrated scenario and prompts; participants discuss decisions and coordination. | Testing understanding of roles, plans, communications, and decision-making. | Discussion can reveal unclear procedures, but does not by itself show whether staff can carry out actions in practice. |
| Drill | Participants practice a specific action or process in a controlled setting. | Checking a defined operation such as notification, patient accounting, or a particular communication procedure. | Set boundaries and safety controls so simulated activity is not mistaken for a real event. |
| Functional exercise | Participants perform selected response functions while controllers provide scenario information; evaluators observe decisions and actions. | Testing response coordination and how plans, people, and processes work together without necessarily staging a full-scale event. | Requires clear control, evaluation, and operational coordination arrangements. |
| Community-based full-scale exercise | Multiple organizations participate in a more operational response to a simulated incident. | Testing coordination across facility and community response partners. | Coordinate scope, communications, and safety with participating organizations; availability and regulatory use depend on the applicable rule. |
A tabletop is a good choice when the question is whether leaders understand what decisions to make and whom to coordinate with. Use an operations-based exercise—a drill or functional exercise, for example—when you need to see whether selected actions and processes work. A community exercise can test interagency coordination. If that is not accessible, some provider rules permit a facility-based alternative, but the accepted substitute varies by category.
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Under the 2024 edition of 42 CFR 482.15(d)(2), hospitals exercise their emergency plan at least twice each year. One exercise each year must be a community-based full-scale exercise or, when that is not accessible, a facility-based functional exercise; hospitals also conduct an additional annual exercise from the options permitted by the rule. A real emergency that requires activation of the emergency plan can exempt a hospital from its next required community-based full-scale or facility-based functional exercise. These are hospital-specific requirements, not a schedule for all healthcare facilities. Check the current regulation and any requirements applicable to your certification type. 42 CFR 482.15
Prepare the exercise and assign roles
Once the objective and format are set, define the scope, scenario, participating departments, outside partners, evaluation approach, and safety arrangements. Prepare scenario information and prompts in advance, and give participants enough briefing to understand how the exercise works without coaching them toward the expected decisions. ASPR’s Medical Response and Surge Exercise materials align healthcare exercise design with HSEEP principles and emphasize defined roles and early senior-leader engagement. ASPR MRSE Situation Manual
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- Exercise lead: Sets the scope, confirms leadership support, and coordinates facility departments and outside partners.
- Facilitator or controller: Guides discussion or delivers scenario information in a controlled, consistent way.
- Participants: Perform or discuss the actions called for by the objectives.
- Evaluators: Observe relevant actions and decisions and record evidence against the objectives.
- Safety contact: Monitors operational boundaries and can pause the exercise if a real safety concern arises. Assign this role explicitly for live or operations-based activity.
Prepare a participant briefing, scenario narrative and injects or discussion questions, evaluator notes, and an evaluation plan. Brief everyone on the objectives, exercise boundaries, safety limits, and how to distinguish a real incident from simulated activity. For live drills, coordinate with facility operations and community partners so the exercise does not create confusion or disrupt care.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Conduct the exercise and evaluate performance
- Open with a briefing. State the objectives, scope, rules, safety limits, and what participants should do when they receive simulated information. Explain how anyone can flag an actual emergency or stop unsafe activity.
- Deliver the scenario consistently. Present information at planned points through the facilitator or controller. Use prompts that let participants make decisions rather than supplying the answers.
- Observe against the objectives. Evaluators should document actions and decisions, not grade individual staff. Note what occurred, when it occurred, who or which function acted, and what evidence supports the observation.
- Track operational details. Keep a timeline and record relevant communications, handoffs, resource requests, patient-accounting steps, and points where written procedures are unclear or unavailable.
- Manage safety and real-world interruptions. Keep exercise activity within the announced boundaries. If a real incident or safety issue arises, pause or stop the exercise under the procedure given in the briefing.
Capture strengths as well as gaps. A useful evaluation describes what the facility was able to do and where a plan, communication route, resource, or assigned responsibility did not support the objective.
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Hold a short hotwash soon after the exercise while participants’ recollections are fresh. Gather evaluator observations, participant feedback, and relevant logs. Use the evidence to prepare an after-action report and an improvement plan. For each corrective action, record the issue to address, accountable owner, target date, resources needed, and how completion or improved performance will be verified. Schedule a retest when the action requires practice or demonstration, rather than treating the written plan as proof that the gap is closed.
For hospitals, 42 CFR 482.15 requires analysis and documentation of responses to exercises and emergency events, with revisions to the emergency plan as needed. It also requires the training and testing program to be reviewed and updated at least every two years and emergency preparedness training at least every two years. Those are hospital requirements under the cited rule; other provider types may have different provisions. 42 CFR 482.15
Feed the findings into the next planning, training, exercise, and resource-allocation cycle. ASPR’s preparedness capabilities recommends using after-action findings and improvement plans to inform continuing preparedness work. ASPR preparedness capabilities
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